Comment on EPA proposed refinery rules
- In general, refiners are still in the mode of resisting new government regulatory initiatives and are not acknowledging that reducing pollution is not only good for the environment, but also has an economic return. It is not sufficient to just address current operations in order to establish effective emissions reduction programs. Improvements must begin at the plant design stage in order to eliminate or minimize flaring by integrating flare gas recovery systems, design for smooth start-up and shutdown of process units without flaring, and designing coking units with completely enclosed coke handling systems, to mention a few important areas. Procedural changes and new technology must also extend to plant maintenance. For example, improved monitoring and repair of the seals on floating-roof tanks is essential, as is the use of modern infrared sensors for detecting leaks at valves, pumps and flanges.